Reversing the Expatriation of Profits Offshore Act

Summary

Reversing the Expatriation of Profits Offshore Act - Sets forth the following conditions in which a foreign incorporated entity shall be treated as an inverted domestic corporation for purposes of taxation: (1) if such an entity acquires substantially all properties held by a domestic corporation or substantially all of the properties constituting a trade or business of a domestic partnership; (2)at least 80 percent of the stock (by vote or value) is held by former shareholders (or partners, in the case of a partnership) of the domestic corporation or partnership (with certain exceptions); and (3) if the "expanded affiliated group" lacks substantial business activities in its country of origin compared to its total activities. Sets specific rules covering "inversion gains" of certain "acquired entities" and party transactions of such entities not covered by the above provisions, including: (1) that taxable income of "inversion gains" of such entities cannot be offset; (2) that tax credits shall not be permitted to be used against tax on "inversion gains" of such entities; and (3) that such entities submit to the Secretary of the Treasury an annual prefiling, advance pricing, or other agreement specified by the Secretary. Establishes penalties for failure to make such agreements. Modifies limitation on interest deduction for such entities. Invalidates certain transfers of liabilities deemed to be aimed at avoiding the Act. Increases scope under which the Secretary may act to modify reinsurance agreements to take account of the amount of taxable income of each party. Defines "acquired entities, "inversion gain," and "expanded affiliated group."

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Documents

6 official files

• Reported to Senate (text)

  Reported to Senate · EN · 28 June 2002

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• Reported to Senate (PDF)

  Reported to Senate · EN · 28 June 2002

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• Reported to Senate with amendment(s)

  summary · EN · 28 June 2002

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• Introduced in Senate (text)

  Introduced in Senate · EN · 11 April 2002

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• Introduced in Senate (PDF)

  Introduced in Senate · EN · 11 April 2002

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• Introduced in Senate

  summary · EN · 11 April 2002

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